The following guest essay was written by Paul Symanski. Paul is an electrical engineer with expertise in solar energy, and shares his views on why solar power often faces unnecessary headwinds.
To anyone who has ever spent a day in Arizona’s Valley of the Sun, it is obvious. The sunniest state in the nation is blessed, cursed, with a fierce sun. Yet, as one explores the landscape, artifacts of the capture of solar energy are conspicuously absent. This dearth is true for solar electric, domestic hot water, passive solar design, and even for urban design. It is as if the metropolis stands in obstinate defiance against the surrounding desert and its greatest gift.
Yet, the incessant sun is a constant agitator. Even visitors happily distracted by the Valley’s many amenities will remark while lounging by the pool, drinking in the clubhouse, or enjoying a repast on a misted patio, “Why doesn’t Arizona use more solar energy?”
Solar Tipping Point
One answer to this persistent question can be found once one comprehends that Arizona is where it first occurred: where solar energy first became economical.
Around the turn of the millennium, four decades after its destiny was foretold, an investment in electricity generated by an on-site photovoltaic system became a better investment than traditional investment vehicles. Finally, solar energy had become economically transcendent. Because of its abundant solar resource, solar energy’s transcendence occurred in the center of the desert Southwest, in sunny Arizona. It may not be mere chance that this tipping point coincided with the world’s peak production of petroleum.
The concept of “grid parity” has been promulgated by an energy regime that sees the world through grid-centric eyes. A more accurate and revealing comparison is investment parity. This approach more completely – and perhaps more directly – accounts for the myriad hidden costs embedded in the economics of the world’s energy system. Both the recent economic troubles and the fact that the solar tipping point occurred during an historical low for electricity prices in Arizona reinforce the validity of economic ascendancy of solar energy.
Implicit in the concept of grid parity is an ultimate arrival where both sides rest in balance upon the fulcrum. This subtle point of terminology further invalidates the utility of the concept of “grid parity”. The balance will likely be a brief moment of hushed breath . . . before the tipping continues in favor of solar energy.
The concept of grid parity also establishes a false dichotomy that reveals the term to be an indirection. Solar energy should be one of a multitude of energy sources to be impartially and intelligently incorporated into a flexible network of energy sharing. The concept of grid parity is a creation of a hierarchical system of centralized generation and distribution. Like the system that created it, the term ‘grid parity’ should be recognized for what it is.
The concept of a tipping point is a more appropriate metaphor. It is this tipping point that those favored by the status quo vigorously resist.
It is crucial that energy costs be accurately accounted in order to establish valid policies. Yet, in any forum where energy is discussed (present company excepted), retail energy costs are typically presented as an average, or as a range of values. Even in conversations amongst economists, engineers, scientists, business leaders, policy makers, and others who help guide our energy future, superficial valuations proliferate. Blunt statements of cost nearly always exclude associated economic, competing, and externalized costs. More dangerously, such simplification disguises a complex and telling reality.
The key observation – and the linchpin of the Rate Crimes exposé – is that the avoided cost value of solar electricity and other energy management strategies has long been dramatically lower than the retail cost of electricity under particular rate plans.
The graph below plots the avoided cost value of on-site solar electricity against retail energy costs under the Arizona Public Service E-32 commercial rate schedule for the summer season. The ranges of kilowatt demand and kilowatt-hour consumption reflect those of small businesses.
The avoided cost value of solar electricity is half that of the retail cost of electricity for a great portion primarily because of the uncontrollable billing demand, and a precipitous declining block rate structure compounded by the uncontrollable billing demand being used as a multiplier for the extents of the expensive initial block.
Of the hundred largest electric utilities (by customers served), fourteen are located in the sunny Southwest (excluding the unregulated utilities in Texas).
Of these fourteen, three have commercial rate plans with structures that most defeat the value of solar energy and energy conservation measures. These utilities are: Arizona Public Service, Salt River Project, and Tucson Electric Power. All are Arizona utilities.
The Arizona rate schedules provide an enormous subsidy and encourage prodigal consumption by discounting energy to the largest energy consumers. This was historically a common situation in other places as well. However, Arizona is special due to its extraordinary solar resources.
The pricing system redirects costs from any apparent savings in the residential and industrial sectors into the small commercial sector. Small commercial ratepayers have less capital, have fewer person-hours to commit to unusual projects, have less-diverse expertise, and are often constrained from making modifications to their premises. The redirection of costs into this captive market creates a hidden tax through the higher costs of goods and services, and through the subsequently higher sales tax charges.
Furthermore, while more fortunate homeowners can avoid energy costs by investing in subsidized solar energy, renters remain a captive market.
As you may surmise, nearly the entire Arizona economic and political system is complicit. Beyond Arizona’s borders, the state’s electricity generation from coal and nuclear sources remains the West’s dirty little secret. Environmentally conscientious Californians can nod appreciatively at their Tehachapi and San Gorgonio Pass wind farms; while behind the turbines, on the eastern horizon, the cooling towers and smokestacks of Arizona keep bright their nights.
All Arizonans need to be able to gain full value for investments in energy conservation and in solar energy. Until Arizona’s repressive rate schedules are reformed, energy efficiency measures and solar energy in the nation’s sunniest state will have diminished value. This diminishment of the value of solar energy affects all of us by delaying a cleaner energy future.
Paul Symanski is an electrical engineer, designer, human factors specialist, marketer, machinist, graphic artist, musician, LEED AP, and economist born of necessity. He is experienced with renewable energy, including expertise in solar energy both in practical application and in the laboratory. He is also a competitive masters-level bicyclist. ratecrimes [at] gmail [dot] com
53 thoughts on “Rate Crimes: Impeding the Solar Tipping Point”
“electrical engineer with expertise in solar energy”
But no experience making electricity.
Took a look at his site. Paul spends most of his time explaining what is wrong with nuclear power.
If someone is telling you that PV is a good investment, look for the scam. A $40k solar system may be a better investment than a $40k.
What is the ROI or payback period?
He does seem to be a bit of an anti-nuke freak! Can't look to him for much factual information on that point.
No doubt the rate structure is not a positive thing but I have trouble understanding his great concern about renters.
The Arizona Power Commission is busy allowing all CSP's being planned/built to use the standard old cooling tower – a water monster in the middle of the desert. They consume a similar amount of water resources as the nukes do.
They should be insisting on either air cooling with it's penalties or Heller cooling towers. The CSP's are long term consumers of a commodity already in short supply – water.
Gotta call bull**** on this one. Paul seems to think there is some kind of conspiracy between the politicians, regulators, and utilities to provide affordable, reliable, power 24/7 to the citizens of Arizona. How is that a bad thing?
Alternative energy proponents want to have it both ways. They cry about externalities. But then want access to the grid at peak times without concerns with the externalities the intermittancy of renewables create. Somebody has to provide power for the other 16 hours a day or so that PV solar doesn't work or for the times when the wind doesn't blow. Renewables get to cut to the front of the line at peak demand with NO obligation to serve.
May I suggest further exploration to answer your question: http://ratecrimes.blogspot.com/2009/05/money-from-sun.html
The facts explored in "Fire and Water" speak for themselves.
Because of water constraints, nuclear energy – at least, as it is currently implemented – proves to be an unsustainable source of energy in a desert.
We would all welcome sustainable solutions. Can you provide details of the solutions you introduce?
A "Conspiracy of Dunces", perhaps.
You seem to misunderstand my position: I am very much concerned that the living and future citizens of Arizona and elsewhere receive affordable, reliable, and less toxic power.
The growing gap between power demand and availability should be apparent. http://ratecrimes.blogspot.com/2009/07/filling-gap.html
Your claims of affordability require defense. Especially, when the "externalities" of water consumption, waste management, and the Price-Anderson Nuclear Industries Indemnity Act (to mention a few) are considered.
Intermittency has been addressed on the Rate Crimes blog.
This complex issue will be addressed further.
I hate hyperbole.
I Really, Really hate it when someone that doesn't agree with you is branded a "Criminal."
This is cheap sensationalism that tends to generate heat, not Light.
Having said that, I Would like to see a fairly large PV plant built outside a large Southwester city. Phoenix would be fine. It would be interesting to get the "real-world" numbers after a year, or so, of operations.
I followed some of his arguments down into the E-32 rate structures. You can always find imperfections in a simplified rate structure, but E-32 attempts to reflect actual utility costs. It's not some grand conspiracy to crush solar in favor of the "evil nukes".
I found no support for his claim that Arizona solar ROI is in the 6-8% range delivered by the stock market over time. That'd require 20 cents/kWh and AZ rates are simply not that high.
It is true PV will first become economical in desert s/w locations where it can offset expensive peaking power. But it's not there yet, especially not for rooftop.
There is strategic value in hyperbole. For example, Jim Kunstler's "Clusterf*** Nation".
In case you are unaware, Tucson Electric Power has a laudable solar program that includes a large 4.6 MW array near Springerville, AZ.
The facts are evident. The value of solar energy and energy conservation measures is defeated by the structure of the E-32 rate schedule. The rate schedules are repressive and result in a hidden, regressive tax.
The phrase, "evil nukes" is hyperbolic and misrepresentative of the Rate Crimes analyses and commentary. Your use of quotes is inaccurate if you meant to assign such conclusions to Rate Crimes.
Nuclear power may have its applications. However, it suffers from very serious constraints that are currently being ignored.
You said, "I found no support for his claim that Arizona solar ROI is in the 6-8% range delivered by the stock market over time. That'd require 20 cents/kWh and AZ rates are simply not that high."
Analysis shows that in Arizona an investment in supplemental, on-site solar electricity with existing incentives frequently outperforms traditional high-risk investments. Even without incentives, the solar investment realizes equivalent returns when more fairly compared with low-risk investments. The analysis methodology has long been published. The results have been independently and repeatedly confirmed. You are welcome to repeat the analysis.
Regardless of precise ROI, even a proximate result suggests that solar energy's value is better than competing energy sources when the subsidies and externalities of those alternatives are considered.
These analysis was first performed in 2003-2004, during the historical low of prices for electricity in Arizona . . . and before the market tanked.
I couldn't possibly take seriously anyone who operates a website named thusly. Whatever Kunstler has to say, he'll just have to say it to someone else.
OK, let me see if I understand your argument. You claim that Arizona Public Service's E-32 rate plan somehow discriminates against PV solar because selling power at $0.11438/KWh is less than APS's avoided cost. And if the TRUE cost of peak power were charged somehow that would make solar competitive. Is that right?
First of all, that is total nonsense. Henry Hub natural gas today is selling for $3.75/MMBTU. Let's assume that it costs $2.00 to deliver this gas to a simple cycle power plant somewhere in AZ. Using a heat rate of 12,000 BTU/KWh, you are looking at a fuel cost of $0.069 per KWH. Add $0.025 for capital recovery on the turbine, and you get an avoided cost of $0.094. I don't recall any solar facilities able to crack the $0.10 barrier without massive subsidies or tax breaks, if they could we'd see solar all over the place.
Your summary is incorrect. The reasons why the E-32 rate plan represses the value of solar electric energy and energy conservation measures is clearly explicated on the Rate Crimes Energy Blog.
Many who struggle to escape the big energy paradigm fail to recognize that *not* purchasing energy from the grid is often your best investment. Avoiding these costs would be an even better investment if the rate schedules were not so repressive.
You said, "if they could we'd see solar all over the place."
I recommend only that solar be implemented where appropriate and economical. This does include much of Arizona. Solar should also be implemented at an appropriate scale and integrated with other energy sources within an effective distribution network.
RC, if I suggest that you are shoveling a load; try not to waste time with a link to another load of BS.
If you want to do business in the electricity generating field you have to present your information in a straight forward manner that others in the industry can understand. You sound like a con artist. I suspect you are.
The problem with solar is not cost. However, if as you claim, PV produced electricity lower than replacement cost; then TEC would be expanding Springerville. If you dig a little deeper, you will find that there LFG project is a bargain by comparison.
Last psot was Kit P
You said, "[…]then TEC [sic] would be expanding Springerville."
I suspect that TEP has found the appropriate scale for their purposes. I have no criticism of their approach to implementation. Tom Hansen, the Vice President of Environmental Services at TEP, is a exceptional engineer. Though, I remain critical of the company's pricing policy.
I can only present the facts and analyses. It is up to you to decide whether to invest the time to seek edification.
RC – let's use your numbers then. In a post in May you claimed that PV installed in AZ was $6.50/W on the low end. Let's assume that an investor wants a 7.5% rate of return on their money and that your PV solar produces 1 watt of power for 8 hours per day 365 days per year. I'm spotting you taxes, amortizing the capital, and being generous with the power output.
$6,500/KW * 7.5% / (365 days * 8 hrs/day) = $0.1670 /KWh
In my earlier post I showed you how a simple cycle peaker can produce power at less than $.10/KWh.
So how is it that solar is being discriminated against. It appears to me that APS's E-32 rate and its solar rates seem pretty reasonable to me, given the relative costs to produce power.
Builders should be encouraged to put up houses with solar roofs,especially in states like Arizona. A $30,000 system over 30 years would add about $100 to the house note. After market systems have to be financed at a higher rate,and the interest isn't deductible. And solar roof tiles look so much better than panels. I know it makes economic sense. Rates will obviously rise over the next 30 years,so why aren't builders doing it?
You said, "In a post in May you claimed that PV installed in AZ was $6.50/W on the low end."
That post referred to a price from a 2004 article. The price used was intentionally low in order to emphasize and to indicate to the industry the tipping point price. In actuality, at the time, that price was valid for larger (4kW+) systems. However, at the time even residential rate schedules kept the size below 2kW before diminishing returns occurred. The Arizona solar industry was not pleased to recognize this fact.
The analysis methodology is described on the Rate Crimes Energy Blog and in the Home Power article.
At the most basic level, it is a competitive investment analysis between on-site solar electricity (with and without incentives) and traditional investments. The analysis grew out of a very simple question, "(When) will I have more money in the bank if I make an investment in on-site solar energy."
The answer for residential "ratepayers" in Arizona is about 7 years with incentives. The 7.15% historical long-term average annual return of the S&P 500 was the standard used.
The ROI is applied to each side of the comparison and each side includes reinvestment of periodic returns. The time value of money is fully accounted.
You employ a more traditional approach that is overly simplistic. Your approach also omits the complexities of the rate schedules.
The motivations of builders are inspired by quarterly profits and the impulses of their customers. The whims of wives to have the concrete comfort of upgraded kitchen cabinets has trumped the abstract value of decades of steady, but less showy electricity.
Your "encouraged" is the key thought. What do you suggest?
But when PG&E asked state regulators to approve a deal for the output of a proposed 92-megawatt eSolar plant, it did not request a rate increase. It said the power is cheaper than other power available when the plant produces electricity. Utilities pay more for power when demand is high, such as on hot summer days.
Solar Tower has Makers Beaming.
Eventually, the true numbers (whatever they are) will out.
You said, "Eventually, the true numbers (whatever they are) will out."
True enough. However, the key word is "eventually". Analysis shows that the rate schedules in the sunniest state, Arizona – and now only in Arizona – repress the value of solar energy and energy conservation measures. Because of this obstruction, the tipping point for solar electricity has been delayed for at least a decade.
The question remains: Have we been delayed too long? Also, will there be further delay?
RC – I guess I'm just simple then.
I enter our monthly electricity usage and charges monthly and chart power usage compared to other years to see how we are doing. I also keep a page that looks at purchasing hybrid cars and PV solar arrays for our house.
Using 5% ROI and $4.80/W installed. It is still a lousy investment, something like a 25 year payout. Besides, I've got better things to do with my time than maintain a PV solar system when I can buy power from the grid at $0.11/KWh.
If the W-M bill passes, distributed PV will qualify for a 3X renewable credit. At the estimated $0.018/KWh for RECs, that would likely change the economics – at least for me. Because some poor sap who didn't have $15,000 for a PV system would be paying me.
The problem isn't that utilies are mispricing PV solar. The problem is that it is still too expensive.
I'm still waiting for my $1/W solar panels. Anyone? Anyone? Bueller?
KoK, I've thought for awhile that the magic number would be $9,999.00 for a decent six, or seven kilowatt system, installed.
Can we have this article again, this time in English?
Am I the only person that got about 4 paragraphs in and thought, "this guy is either deliberately using complex prose to confuse (and bedazzle) this audience, or he's just plain crap at explaining things"
Also, I don't buy the concept that the rate structure is wrong just because it descriminates against one particluar generator type.
I'd have to see some empirical evidence that, without subsidies, solar could compete in some new type of rate structure thats acceptable to rate payers, tax payers and existing utilities.
I suspect that some hypothetical new rate structure that favours conservation & solar peak power, would not find favour with rate payers or any existing utility.
It sounds as if you're doing some excellent analysis. You didn't say where you live. What are your solar resources?
You said, "The problem isn't that utilies are mispricing PV solar. The problem is that it is still too expensive."
I speak only of Arizona utilities. There is a near-perfect correlation between repressive rate schedules and the utilities in the sunniest state. You may draw your own conclusions from that extraordinary fact.
Although pricing is a problem in the context of surcharges for "green energy", the central problem is not pricing but the structure of the pricing.
In comparison, solar is not too expensive where the sun shines. Rather, the true costs of electricity generated from coal and nuclear sources have been too long hidden.
The cost trends are rapidly improving for solar, in stark constrast to that of traditional fuel sources.
Six years ago I stated to my Arizona audiences that if they had a 401K (without matching) but had no solar on their home, then they were missing their best investment. I wonder, how have those 401K plans faired?
Andy +1. I have yet to understand RC's brilliance.
There aren't a lot of time of day usage programs in the U.S. I don't think that would even help solar. Here is one from Alliant in Iowa. Summer peak power is $0.146/KWh and off peak is $0.05. I would say you'd need peak power in excess of $0.20 before PV solar had a chance.
Besides, if AZ load is primarily summer AC, chilled water storage systems like the one in Chase Field in Phoenix might make more sense than PV.
You said, "I don't buy the concept that the rate structure is wrong just because it descriminates [sic]against one particluar generator type."
It goes far beyond generation. The rate schedules also defeat the value of energy conservation measures.
You said, "I suspect that some hypothetical new rate structure that favours conservation & solar peak power, would not find favour with rate payers or any existing utility."
Those alternative rate structures are not hypothetical. They exist nearly everywhere but in Arizona.
If you find the prose to be too challenging then there are many images to assist you on the Rate Crimes blog.
You said, "There aren't a lot of time of day usage programs in the U.S. I don't think that would even help solar."
As is stated in Solar Derated, "The economic value of solar electricity is not necessarily determined by the price you pay for electricity under your currently subscribed rate plan. Rather, it is determined by the plan with the least expensive energy for your consumption pattern from all the rate plans available in the market for your sector and for which you are qualified to subscribe."
You said, "Besides, if AZ load is primarily summer AC, chilled water storage systems like the one in Chase Field in Phoenix might make more sense than PV."
How much water would be required to keep several million people cool during arid Arizona's summer peak?
You said, "Whatever Kunstler has to say, he'll just have to say it to someone else."
You're joking, right? Are you saying that you are not familiar with James Howard Kunstler? If this is the case, then I encourage you to explore his thinking.
You might begin with his book, "The Geography of Nowhere".
rufus, I agree with you on the hyperbolic "Crimes". I can't stand Kunstler either, the few times I've read his blog. The first post I read, he ranted on architectural aesthetics. That was much more heat than light. I think you aren't missing much by not reading Kunstler.
Andy+2. Also, the graph included in this guest post is much more confusing than the prose.
Clee said, "I can't stand Kunstler either, the few times I've read his blog. The first post I read, he ranted on architectural aesthetics. That was much more heat than light. I think you aren't missing much by not reading Kunstler."
You might find his book more coherent and cogent than his blog.
Clee said, "Also, the graph included in this guest post is much more confusing than the prose."
Clee, can you be specific? What do you find confusing? How would you improve the graph?
RC, I've read so many of his quotes over at the Oil Drum that I feel like he's my next door neighbor.
None of the "quotes" that were attributed to him made any sense to me.
I'm an Ex-Marine, Vietnam Vet, long-time "Republican" Voter, businessman, retired from the Insurance business.
I think we might have a few "rough" years when peak oil hits (I do believe in "Peak Oil,") but I am as far from being a "Doomer," or "Revolutionary" as anyone you could imagine.
I'm not interested in reading more nonsense, from any other faux-economist loons. I've read enough to last me a lifetime.
"Your "encouraged" is the key thought. What do you suggest?"
I've suggested mandates before. I think new homes and businesses,especially in the sunbelt,should have solar shingles. That way,the system can be financed along with the house. Of course,I've also suggested a ban on internal combustion engines. All we've done on energy security is flap our lips energetically. We should get serious…..and soon.
The biggest problem I have with the graph is the what the vertical axis represents. But more on that later. The most glaring confusion I have with the graph is that no Demand Based charges apply to Peak Demands under 20 KW. So why does your graph vary at all with Peak Demand?
RC – I live on the western edge of Houston. Our solar insolation averages just under 5 KWh/m2/day. I would agree that in the US, someplace like Phoenix is about as good as you can get, maybe 6-6.5.
And sure, if I had cashed out $50k of my 401K in 2008 and invested in PV solar I would be way ahead of the game. Or I could have bought 2,500 cases of beer and been ahead.
I'm still confused, if the value of solar isn't determined by price, then how does one value it? Last time I opened my electric bill they wanted money, but I suppose I could draw them a picture or write a Haiku and tell them they really shouldn't just determine the value of me as a customer by price.
I think you and your blog are exceedingly silly.
BTW – chilled water systems are closed loop, no water losses. You chill brine down to around -5 C or so to be used during the day to cool a building. The baseball stadium in Phoenix uses such a system housed in an old warehouse across the street. They did both to save operating costs and becuase installing conventional AC would have required massive upgrades of the downtown transmission systems.
Thank you for spotting the error. An updated graph will soon be published.
A detailed explanation of the graph is provided at Solar Derated.
The vertical axis is a ratio of the avoided cost value of the electricity from a solar electric energy system providing 10% of kilowatt-hours consumed to the retail cost of electricity.
All graphs for the rate plan display the kW (demand) scale for consistency. The updated graph will plot a wider range of values.
Agreed! 2,500 cases of good beer might be the better investment. It could lead to many new friends.
The value of solar or energy conservation measures varies with the investor's avoided cost.
You said, "We should get serious…..and soon."
We will, but whether by choice or necessity remains to be seen.
Happily welcoming mandates is not part of our culture. I suggest that we first create transparancy. Few comprehend how energy pricing has repressed sustainable energy solutions. Until the full life-cycle costs of each alternative is accounted, we will continue to thrash.
Well at least we can agree on beer. I like locally produced stuff. Shiner Bock is nice. Often I ride my bike to the neighborhood pub where it is $1.75 a pint. But of course one can't value beer by price alone. Sounds like a plan for the evening!
As I've said many times, I'm not against PV solar. It just hasn't reached a price point where it is competitive with competing generation technologies, even when you factor in externalities like water and CO2. But it has only been the next great thing for the 28 years I've been in the energy business.
Hold the phone! Shiner pints went to $2.25 during happy hour. I'm going to have to cut back.
Regarding the exchange between Maury and Rate Crimes on encouraging builders to go solar, having a proper architectural paradigm for them to tap into would be helpful.
In general, the commentary here, as elsewhere, seems to devolve into a war between 2 legitimate power sources that can and should be working together according to their strengths and drawbacks. Because coal is a stored but limited form of solar energy, logically it should be the back-up alternative.
You've hit the nail in the adobe wall on the head. Energy, design, and construction is a system that has too long been left to too often competing whims. To a large extent, we have foregone the regional vernaculars for a ubiquitous, generic, industrial solution. Industrial economies of scale have their unacknowledged, attendant costs.
You said, "In general, the commentary here, as elsewhere, seems to devolve into a war between 2 legitimate power sources that can and should be working together according to their strengths and drawbacks. Because coal is a stored but limited form of solar energy, logically it should be the back-up alternative."
The problem is complex. Despite what others here have misinterpreted, I am not rigidly opposed to any part of a sustainable solution; even if that part itself is not sustainable.
My position is that the real costs should be made transparent and then be accounted. We cannot have an honest discussion until that occurs.
I believe that as a society we have bowed to expediency without admitting constraints. If there is a chasm in the conversation, I believe that it runs much deeper than simply a selection of energy choices. The gulf lies between Cornucopians and NeoMalthusians.
I sit on the side of cautious risk assessment.
KingofKaty wrote: I'm still waiting for my $1/W solar panels. Anyone? Anyone? Bueller?
I've heard rumors about it for months, but I've finally seen it, though I have no idea if the reseller is real or not and you have to buy at least 50 panels.
All prices FOB Miami
Kaneka GSA-60 60 Watt, 0.90 Imp, 67.00 Vmp $58.80 98 Cents per Watt 2 pallets or more
The distributor, Sun Electronics appears to have been around since 1999 at least, so I tend to think they are real. They say they've been in the solar business for over 35 years.
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